Transfer Pricing& Tax Solutions
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Industries

Sector experience that shortens the conversation.

The partners have advised groups in these industries for decades, including several of New Zealand’s largest companies. We know the transactions, the comparables and the questions Inland Revenue asks in each.

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At a glance
  • 9 sectorsWhere most of our work sits
  • NZ’s largest companiesAmong past engagements
  • Cross-borderInbound and outbound groups
TechnologySoftware, platforms and IP-rich groups with licensing and service flows.
SoftwareSaaS and licence models where the value of IP and the location of DEMPE functions drive the pricing.
AutomotiveImporters and distributors with group pricing, warranty and marketing arrangements.
FMCG and consumer productsDistribution margins, marketing intangibles and procurement hubs.
InsuranceReinsurance, captive arrangements and intra-group services.
Energy and powerInfrastructure funding, related-party debt and guarantees.
PharmaceuticalsLicensing, distribution and clinical cost-sharing arrangements.
Industrial productsManufacturing, contract manufacturing and supply chain restructures.
Financial servicesIntra-group funding, guarantees and treasury functions.
Experience

The kind of work we do.

Financial transactions

Cross-border financing arrangement

Challenge
A New Zealand subsidiary received significant funding from an offshore related party. The group’s global policy did not reflect New Zealand’s rules for related-party debt.
TPTS approach
Economic analysis of the borrower’s credit profile, pricing of the loan under New Zealand’s rules and the OECD guidance, and documentation of the arrangement.
Outcome
A defensible transfer pricing position supported by documentation that reconciles the group policy with the New Zealand result.
Financial transactionsTransfer pricing documentation
Disputes

Inland Revenue transfer pricing review

Challenge
Inland Revenue opened a review of a group’s related-party arrangements after a risk review questionnaire.
TPTS approach
Risk assessment of each transaction, targeted economic analysis, a technical response and direct engagement with Inland Revenue’s transfer pricing specialists.
Outcome
The matter was resolved, with documentation strengthened so the position holds for future years.
Disputes and controversyBenchmarking
APAs

Advance pricing agreement for an inbound loan

Challenge
A significant inbound loan carried enough exposure that the group wanted certainty rather than an annual argument.
TPTS approach
Feasibility assessment, preparation of the application and economic support, then negotiation with Inland Revenue.
Outcome
An agreed position for the term of the APA, with annual reporting handled by TPTS.
Advance pricing agreementsFinancial transactions
Talk to a specialist

Let’s talk about your situation.

A confidential discussion with a partner costs nothing and usually tells you within half an hour whether there is something to do. Call Mark or Ranesh directly, or send a brief outline and we’ll come back to you within one business day.

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Mark Loveday · Partner+64 274 899 336
Ranesh Singh · Partner+64 274 899 388
Transfer Pricing& Tax Solutions